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The European Accessibility Act: is your business covered? Thresholds and exemptions

The European Accessibility Act has applied since 28 June 2025. Not every organisation is in the same boat: here is who is covered, who is exempt, and where audio fits without pretending to be compliance.

Since 28 June 2025, the European Accessibility Act (Directive (EU) 2019/882) has applied across the Union. Most of what is written about it speaks to one sector at a time: banking, e-commerce, the press. Yet the question that comes up first, and is rarely answered head on, is more basic: is my business covered, and if so, how far does the obligation reach? Answering honestly means separating three things the text is happy to blur.

What the act actually targets: named products and services

The act does not say "every website must be accessible". It lists products (computers, smartphones, e-readers, self-service terminals, payment terminals) and services (e-commerce, consumer banking, electronic communications, e-books, passenger transport, access to audiovisual media services). If your activity falls into one of these categories, you are in scope, and the accessibility of your website and app is part of it.

Conversely, a company blog, a brochure site, or a content publication that sells nothing directly is not, in itself, a "service" in the meaning of the directive. That does not mean accessibility is irrelevant to it (other frameworks exist, and it is good practice regardless), but the act's binding obligation does not attach to it automatically. We covered online shops in what e-commerce sites must do now and finance in the act applied to banking and financial services.

The microenterprise exemption, often misread

This is the point people take false comfort in, or worry about needlessly. A microenterprise, in the directive's sense, employs fewer than ten people and has an annual turnover (or balance sheet total) of two million euros or less. A microenterprise that provides a service is exempt from the act's accessibility obligations. That is a real exemption, not a lighter version of the same duty.

Two caveats matter. First, the threshold is assessed on the whole company, not the team that runs the site: a fifteen-person firm where three people handle digital is not a microenterprise. Second, the exemption applies cleanly to services, less so to products: a microenterprise making a covered product gets administrative relief, but the product's accessibility requirement does not vanish as neatly. If you are near the threshold, this is not a call to make on gut feeling.

Disproportionate burden: a door, not an escape hatch

The act allows a covered business to be relieved of certain requirements where meeting them would impose a "disproportionate burden". Many read that as a convenient way out. It is one only under three conditions: the assessment must be documented, based on objective criteria (the cost of compliance weighed against the company's resources, and the benefit to the people concerned), and reviewed regularly, in particular when the service changes. A claim asserted without a file will not hold in front of a market surveillance authority, and the burden of proof sits with the business, not the complainant.

Put plainly: disproportionate burden protects the small operator who would otherwise have to rebuild everything overnight, not the one who would rather do nothing. And it is demonstrated, not declared.

Where audio fits, without pretending

Once you have established that you are covered, you still have to act. The technical reference is the European standard EN 301 549, which points, for the web, to WCAG level AA criteria. Compliance starts with page structure: contrast, keyboard navigation, alternative text, labelled forms. No voice feature replaces that foundation, and we say so plainly in audio version versus screen reader, which are not the same thing.

An article's audio version plays a different role: it serves people who struggle to read on screen through fatigue, mild visual impairment, or a reading difficulty, without replacing the screen reader that a blind person relies on. It is a comfort and access add-on, not a compliance checkbox. Our accessibility and WCAG page explains how WeDispatch fits into that logic, and our piece on news websites under the act shows how it plays out for publishers.

Where to start in practice

If you are not yet sure whether you are in scope, the first step costs nothing: map your activity against the list of covered services, check the microenterprise threshold, and write down the result. If you are covered, an accessibility audit of your key journeys (product page, checkout, account area) will tell you where you actually stand, far better than an intuition. Audio comes next, as a genuine improvement to the experience for part of your audience, once the foundation is in place.

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